Effective as of May 25, 2018.
The aim of this Policy is to inform you of the following:
- What personally identifiable information is collected from you through the web site, how it is used and with whom it may be shared.
- What choices are available to you regarding the use of your data.
- The security procedures in place to protect the misuse of your information.
- How you can correct any inaccuracies in the information.
We collect your personal data in the following ways:
- When you sign up for an Braveway Service – We collect certain personal data so you can use the CA Cloud Service such as your name, email address, and phone number.
- When you pay for an Braveway Service – We collect certain payment and billing information when you register for certain paid Services. You might also provide payment information, such as payment card details, which we collect via secure payment processing services.
- When you use our support channels – The Braveway Services also include customer support, where you may choose to submit information regarding a problem you are experiencing with a Braveway Service. Whether you designate yourself as a technical contact, open a support ticket, speak to one of our representatives directly or otherwise engage with our support team, you will be asked to provide contact information, a summary of the problem you are experiencing, and any other documentation, screenshots or information that would be helpful in resolving the issue.
- Content you provide through our websites – The Braveway Services also include our websites owned or operated by us. We collect other content that you submit to these websites, which include social media or social networking websites operated by us. For example, you provide content to us when you provide feedback or when you participate in any interactive features, surveys, contests, promotions, sweepstakes, activities or events.
We collect this information for these purposes:
- To verify you are the account holder when processing support requests and account changes.
- To communicate with you about Braveway Service-related purposes.
- To process your payment to prevent or detect fraud including fraudulent payments and fraudulent use of the Braveway Service.
- To communicate with you for:
- participation in contests, surveys and sweepstakes,
- promotional purposes,
via emails, notifications, or other messages, consistent with any permissions you may have communicated to us
We are the sole owners of the information collected. We only have access to and collect information that you voluntarily give us via our website, email, ticketing systems, live chat or other direct contact from you. We will not sell or rent this information to anyone.
We will not share your information with any third party outside of our organization, other than as necessary to fulfill your request.
Disclosure to Law Enforcement
We may disclose information to law enforcement agencies without further consent or notification to the subscriber upon lawful request from such agencies. We will cooperate fully with law enforcement agencies.
Your Access to and Control Over Information
In accordance to the General Data Protection Regulation or GDPR, we have implemented additional transparency on how you have access and control over your information.
As available and except as limited under applicable law, the rights afforded to individuals are:
- Right of Access – the right to be informed of and request access to the personal data we process about you;
- Right to Rectification – the right to request that we amend or update your personal data where it is inaccurate or incomplete;
- Right to Erasure – the right to request that we delete your personal data;
- Right to Restrict – the right to request that we temporarily or permanently stop processing all or some of your personal data;
- Right to Object –
- the right, at any time, to object to us processing your personal data on grounds relating to your particular situation;
- the right to object to your personal data being processed for direct marketing purposes;
- Right to Data Portability – the right to request a copy of your personal data in electronic format and the right to transmit that personal data for use in another party’s service;
- Right not to be subject to Automated Decision-making – the right to not be subject to a decision based solely on automated decision making, including profiling, where the decision would have a legal effect on you or produce a similarly significant effect.
In order to enable you to exercise these rights with ease and to record your preferences in relation to how Braveway uses your personal data, we provide you with access to update your information via your Account Settings page.
If you would like to review, correct, or update information that you have previously provided to us, you can contact us at email@example.com. For your protection, we only fulfill requests for the information associated with the particular email address that you use to send us your request, and we may need to verify your identity before fulfilling your request. We will try to comply with your request as soon as reasonably practicable.
Data Retention and Deletion
We keep your personal data only as long as necessary to provide you with a Braveway Service and for legitimate and essential business purposes, such as maintaining the performance of your Braveway Service, making data-driven business decisions about new features and offerings, complying with our legal obligations, and resolving disputes.
If you request, we will delete or anonymize your personal data so that it no longer identifies you, unless, we are legally allowed or required to maintain certain personal data, including situations such as the following:
- If there is an unresolved issue relating to your account, such as an outstanding credit on your account or an unresolved claim or dispute we will retain the necessary personal data until the issue is resolved;
- Where we are required to retain the personal data for our legal, tax, audit, and accounting obligations, we will retain the necessary personal data for the period required by applicable law;
- Where necessary for our legitimate business interests such as fraud prevention or to maintain the security of our users.
This web site contains links to other sites. Please be aware that we are not responsible for the content or privacy practices of such other sites. We encourage our users to be aware when they leave our site and to read the privacy statements of any other site that collects personally identifiable information.
We take precautions to protect your information. When you submit sensitive information via the website, your information is protected both online and offline.
Wherever we collect sensitive information (such as credit card data), that information is encrypted and transmitted to us in a secure way. You can verify this by looking for a closed lock icon at the bottom of your web browser, or looking for “https” at the beginning of the address of the web page.
While we use encryption to protect sensitive information transmitted online, we also protect your information offline. Only employees who need the information to perform a specific job (for example, billing or customer service) are granted access to personally identifiable information. The computers/servers in which we store personally identifiable information are kept in a secure environment.
We use “cookies” on this site. A cookie is a piece of data stored on a site visitor’s hard drive to help us improve your access to our site and identify repeat visitors to our site. For instance, when we use a cookie to identify you, you would not have to log in a password more than once, thereby saving time while on our site. Cookies can also enable us to track and target the interests of our users to enhance the experience on our site. Usage of a cookie is in no way linked to any personally identifiable information on our site.
BraveWay respects your privacy and is committed to maintaining the privacy and confidentiality of personal data we collect. The purpose of our Privacy Statement is to demonstrate our firm commitment to the privacy and protection of all persons who provide personal data to BraveWay and its affiliates. This Privacy Statement describes the ways we collect information from and about you, and what we do with the information, so that you may decide whether or not to provide information to us.
By visiting BraveWay websites or are otherwise providing your personal information to BraveWay via any other means, you are accepting and consenting to the practices described in this Privacy Statement.
For purposes of this Privacy Statement, the term “visitor” includes visitors to our websites who are not yet customers, those who become customers, as well as those who do not become customers; whether you upload information to our websites, download it, or are merely visiting our websites. You can choose not to provide certain information when using our websites but then you might not be able to take advantage of many of its features.
1. WHAT DO WE COLLECT AND WHERE?
The information we collect may include your personal information, such as your name, contact information, financial account numbers, IP addresses, Live Chat Messages, Telephone conversations, product and service selections and orders or other things that identify you individually.
Generally, we may collect information about you in the following manners:
you may provide your personal information to us via chat, email or other written correspondence, telephone calls, web based forms, or other means;
via third party providers; and
BraveWay affiliates located in the European Union may provide BraveWay with personal information about their prospective or current customers.
Links to non-BraveWay Websites
We may provide links to third-party websites for your convenience and information. The privacy practices of those sites may differ from BraveWay practices and are not controlled by BraveWay and covered by this Privacy Statement. We do not make any representations about third-party websites. We encourage you to review their privacy policies before submitting your personal data.
Personal information received from the EU and/or Swizerland
When BraveWay is a data controller – Safe Harbor compliance
BraveWay complies with the U.S.-EU Safe Harbor Framework and the U.S.-Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland. BraveWay has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement, with respect to the personal data we collect from EU and/or Swiss data subjects or receive from our affiliates located in the EU and/or Switzerland, such as information regarding service requests, service orders, handling orders, delivering services and processing payments. To learn more about the Safe Harbor program, and to view BraveWay’s certification, please visit http://www.export.gov/safeharbor/.
We will not intentionally collect or maintain, and do not want you to provide, any information regarding your medical or health condition, race or ethnic origin, political opinions, religious or philosophical beliefs or other sensitive information.
Children’s Online Privacy Protection
Our services are not designed for or directed to children under the age of 13, and we will not intentionally collect or maintain information about anyone under the age of 13.
2. WHAT DO WE USE THIS INFORMATION FOR?
We may use your information to process your service requests, handle orders, deliver products and services, process payments, communicate with you about orders, provide access to secure areas of the Website, recommend merchandise and services that might be of interest to you, to personalize your visit to our Website, and to enable us to review develop and continually improve the products services and offers we provide online. We also use this information to prevent or detect fraud or abuses of our Website and to enable third parties to carry out technical, logistical or other functions on our behalf.
We use visitor information to send information about our company to visitors and to get in touch with them when necessary. We also use the information we collect to improve the content of our websites and as training aides for our employees. Visitors are given the choice at the point when we request their information.
Financial Information and payment card details
We may ask visitors to enter credit card or account information in order to process orders for services placed with BraveWay or its affiliates. Financial information provided via our website or via the BraveWay portal is transferred over a secure connection. We collect this information on a transaction-by-transaction basis and will not authorize the release of the information with anyone not directly involved in processing the transaction. This information may be encrypted and stored for logging purposes in accordance with applicable regulatory requirements.
Credit card numbers are used only for processing payments and are not used for any other purposes. When we use third party service providers for credit card processing services we will enter into a written agreement with such third party ensuring appropriate security and confidentiality measures are in place in safeguarding your personal data.
We use web visit information to measure interest in and develop our web pages and marketing plans, customize the content you view on your web visits based on your activity on past visits, and administer our Website.
We use the visitors’ IP address to help diagnose problems with our servers, and to administer our Websites.
We use web beacons to count the number of times that our advertisements and web-based email content are viewed. We combine web beacon information with cookies to track activity on our website originating from advertisements and web-based email content.
We use the information you provide to us via telephone calls, chat, email, web forms and other communications to correspond with you about services you may be interested in purchasing. If you elect to purchase a service online using a web form, we will use the information to establish your account. The information you submit in writing, such as chat, email, and web form information is archived and may be tied to information that we collect about your web visits. Your telephone call may be recorded for training purposes and we may enter the information you provide via telephone into our systems to use for the purposes described in this paragraph.
3. DISCLOSURE OF PERSONAL INFORMATION
Personal information we gather is for internal use only and will not authorize the release of this information to anyone outside BraveWay (except to third party service providers to BraveWay who perform functions on our behalf but in such event personal information will only be shared to the extent reasonably necessary to perform their functions and they will not be authorized to use it for any other function), unless you have consented to such disclosure.
Should you breach our terms and conditions or website terms, or if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, we may disclose your information to a relevant authority. This may include exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction. In particular, we may release the information we collect to third parties when we believe it is appropriate to comply with the law, to enforce our legal rights, to protect the rights and safety of others, or to assist with industry efforts to control fraud, spam or other undesirable conduct.
We may release the information we collect to third parties, where the information is provided to enable such third party to provide services to us, provided that the third party has agreed to use at least the same level of privacy protections described in this Privacy Statement, and is permitted to use the information only for the purpose of providing services to us.
4. OPTING OUT OF COMMUNICATIONS
BraveWay gives you an opportunity to chose to opt-out of personal data being disclosed to third parties for a purpose incompatible with the purpose for which it was originally collected (except for meeting applicable legal requirements or permitting third party service providers who perform functions on our behalf as described in section 3 of this Privacy Statement), including your opting out of receiving future marketing mailings. We will not use your contact information to correspond with you about our services if you ask us not to. Please send your request to firstname.lastname@example.org. Please note that it may take up to ten days to remove your contact information from our marketing communications lists, so you may receive correspondence from us for a short time after you make your request.
5. SECURITY OF YOUR INFORMATION
BraveWay is committed to industry best practices approaches concerning security measures to prevent the loss, misuse, and alteration of the information in our possession. We use various security measures to protect the information we collect, as appropriate to the type of information, including encryption, firewalls, and access controls. We store information you provide to us on a computer system located in a controlled facility with a limited access. Visitor textual information is encrypted during transmission, our company databases are accessible only by BraveWay employees, contractors, and agents on a need to know basis and who have entered into and are bound by a confidentiality and nondisclosure agreement with BraveWay.
6. DATA INTEGRITY
Personal data we collect is relevant for the purposes for which it is to be used. BraveWay takes reasonable steps to ensure that data is reliable for its intended use, accurate, complete, and current.
7. RIGHT TO ACCESS YOUR PERSONAL INFORMATION
If you believe that any personal information we have about you is incorrect, or is, has been, or might be used inappropriately, please contact us at privacy@BraveWay.com, and we will take steps to correct or delete the information or restrict its use, as appropriate.
BraveWay utilizes the self-assessment approach to assure its compliance with its Privacy Statement. BraveWay regularly verifies that the privacy statement is accurate, comprehensive, prominently displayed, completely implemented and in conformity with the Safe Harbor Principles and conducts its self-assessment on an annual basis to ensure that all relevant privacy practices are being followed. Appropriate employee training is in place and internal procedures for periodically conducting objective reviews of compliance are in place. A statement verifying this self-assessment is signed by a corporate officer or other authorized representative at least once a year.
9. INQUIRIES OR COMPLAINTS
If you have a question or complaint about this Privacy Statement or our information collection practices, please contact us at privacy@BraveWay.com